PROPOSED RIVIERA TUNGSTEN PROJECT MAGISTERIAL DISTRICT OF PIKETBERG WESTERN CAPE PROVINCE FINAL SCOPING REPORT REFERENCE NUMBER: WC 30/5/1/2/2/10110 MR FEBRUARY 2019 PREPARED FOR: PREPARED BY: Bongani Minerals (Pty) Ltd Greenmined Environmental Suite 2.1 On the Greens Unit MO1, No 36 AECI site Golf Village Baker Square, Paardevlei De Beers Avenue De Beers Avenue Somerset West Somerset West 7130 7130 Contact Person: Mr L Koster Contact Person: Ms C Fouche Tel: 060 785 2780 Tel: 021 851 2673 Cell: 083 265 7755 Cell: 082 811 8514 E-mail: [email protected] Fax: 086 546 0579 [email protected] RIVIERA TUNGSTEN FINAL SCOPING REPORT - FEBRUARY 2019 EXECUTIVE SUMMARY The Applicant, Bongani Minerals (Pty) Ltd, applied for environmental authorisation to mine tungsten and molybdenum from a 531.4405 ha area that extends over Portion 1 of Farm 297 RD, Portion 6 (Remaining Extent) of the farm Namaquasfontein 76 RD, and Portion 21 of the farm Namaquasfontein 76 RD. Greenmined will at all times remain independent and will perform its obligations in terms of all relevant Acts, Regulations and Guidelines, as expected from environmental practitioners. All documentation, to date, was based on preliminary data and desktop studies as access to the study area was denied by the landowners, resulting in limited information being provided to all commenting parties. Numerous attempts and letters requesting access to the properties by the applicant was all in vain. Greenmined is unable to provide the I&AP’s and stakeholders with material information with regards to this mining right application and it is therefore clear that the relevant authorities will not be able to make an informed decision, irrespective should it be positive or negative. In light of the above all comments with regards to Greenmined’s alleged incompetence is noted. However, due to the landowners refusal to grant access to the properties that proper studies could not be conducted. Upon commencement, the proposed project will trigger listed activities in terms of the National Environmental Management Act, 1998 (Act 107 of 1998) and the Environmental Impact Assessment Regulations 2014 (as amended 2017) and therefore requires an environmental impact assessment (EIA) that assess project specific environmental impacts and alternatives, consider public input, and propose mitigation measures in cooperation with specialists, to ultimately culminate in an environmental management programme that informs the competent authority (Department of Mineral Resources) when considering the environmental authorisation. This report, the Final Scoping Report, forms part of the departmental requirements, and presents the first report of the EIA process. The Applicant held a prospecting right (WC 30/5/1/1/2/10197 PR) over the proposed mining right application area for tungsten (W) ore, molybdenum (Mo) ore, rare earths, copper ore, zinc ore, gold ore and silver ore that expired during December 2018. Owing to the prospecting outcome, the applicant applied for a mining right for the winning of tungsten and molybdenum. Should the MR be granted and the mining of tungsten and molybdenum be allowed, the Riviera Tungsten project will comprise of activities that can be divided into 3 key phases namely the: (1) Site establishment/construction phase which will involve the demarcation of the site boundaries and required buffer no-go zones pertaining to existing infrastructure and areas of significant importance (such as but not limited to watercourse, wetlands, Critical Biodiversity Areas (CBA) and/or Ecological Support Areas (ESA)) identified during the environmental impact assessment. Site establishment will further necessitate the clearing of vegetation, stripping and stockpiling of topsoil, and establishing site infrastructure. (2) Operational phase that is presently expected to be executed in two phases starting with opencast mining that will progress to underground mining through the use of incline shafts. Excavated material will be processed to produce APT that will in turn be transported from site to an offsite metallurgical plant at Saldanha Bay, from where the sealable products will be exported via the multi-purpose terminal of Saldanha Bay Harbour. 2 RIVIERA TUNGSTEN FINAL SCOPING REPORT - FEBRUARY 2019 (3) Decommissioning phase which will involve the rehabilitation, sloping and landscaping of all affected areas, the replacement of topsoil, and the removal of all infrastructure no longer needed by the landowners. The right holder will further be responsible for the seeding of all rehabilitated areas. Once the full mining area is rehabilitated, the mining right holder will be required to submit a closure application to the Department of Mineral Resources in accordance with section 43(4) of the MPRDA, 2002. The Closure Application will be submitted in terms of Regulation 62 of the MPRDA, 2002, and Government Notice 940 of NEMA, 1998. Preferred Site The preferred site entails the proposed mining of an area within the boundaries of the above mentioned properties. Should additional viable site alternatives be identified during the EIA process, the project team will heed the suggestions and investigate the possibility of implementation thereof. Project Alternatives Project Alterative 1 entails the extraction of the tungsten-molybdenum resource in two phases through opencast- and underground mining operations. Processing of excavated material on site to produce APT that is transported to the Saldanha Bay metallurgical plant, and the export of the final product via the Saldanha Bay harbour. Additional project alternatives can be considered during the EIA process as supplementary information is obtained from the specialist studies, contributed by the stakeholders and I&AP’s, and adjusted by the project team. Technology/Design Alternatives Technology/design principles will be considered by the Applicant and project team during the EIA process. No-go Alternative The no-go alternative entails no change to the status quo and is therefore a real alternative that needs to be considered. In the event that the no-go alternative is implemented the land use of the area will remain that of agriculture, conservation, livestock farming and tourism with the tungsten resources unmined. Amongst others, the socio-economic impact of mining on current, and future agriculture and tourism land uses of the study area will be compared to the status quo and will be considered as part of the EIA process, and discussed in the DEIAR. Public participation process During the initial public participation process the stakeholders and I&AP’s were informed of the project by means of background information documents that were sent directly to the contact persons. Due to the compulsory exclusion period over the holidays, the 30-days commenting period was extended with commenting/registration welcomed from 10 December 2018 to 5 February 2019. An advertisements was placed in Die Burger, with on-site notices placed in noticeable areas. In accordance with the timeframes stipulated in the EIA Regulations, 2014 (as amended by GNR 326 effective 7 April 2017) the Draft Scoping Report was compiled to allow perusal of the report by the I&AP’s and stakeholders. A 30 day commenting period was allowed for perusal of the documentation by the I&AP’s and stakeholders that expired 12 3 RIVIERA TUNGSTEN FINAL SCOPING REPORT - FEBRUARY 2019 February 2019. Comments received on the Draft Scoping Report were incorporated into the Final Scoping Report to be submitted to the DMR for decision making. Registered parties will be kept posted on the progress of the Environmental Impact Assessment process, as well as be provided with an opportunity to comment on the EIA documentation. Scoping Report The scoping report identifies the potential positive and negative impacts that the proposed activity and alternatives will have on the environment and the community as well as the aspects that may impact on the socio-economic conditions of directly affected persons, and proposes possible mitigation measure that could be applied to modify / remedy / control / stop the identified impacts. Plan of Study for the Environmental Impact Assessment Process The aspects to be assessed as part of the environmental impact assessment process will include, but not be limited to, the following: 1. Various alternatives (project, technology, design etc.) that will in turn dictate the design and layout of the proposed project as well as hone the proposed mining method. 2. Upon deciding on the preferred alternatives, the applicability of the listed activities identified in terms of the NEMA EIA Regulations, 2017 will be confirmed and aligned with the most recent proposal. 3. The need and desirability of the proposed activity will be discussed in detail and weighed against the no-go option of upholding the status quo at the study area. 4. The inputs received during the public participation process (first- and second phase) will be assessed and considered by the project team during the EIA process. 5. The findings, recommendations and management measure proposed in the specialist reports will be assessed during the EIA process and incorporated into the DEIAR. The following specialists were appointed as part of the project team: Agricultural Impact Assessment (Mr J Lanz); Air, Dust and Noise Impact Study (Enviroworks); Ecological Study (Enviro-Niche Consulting) inclusive of an avifaunal assessment; Engineering Services Report; Freshwater Ecological Assessment (Scientific Aquatic